Health, Safety and Environmental (HSE) Management is an integral and essential part of the way we do our business and is considered an equal part of the wider system for the management of our business.

Through effective management, VONINO aims to be the preferred contractor and the favored employer. The requirements set out in this document constitute the expectations for divisional compliance with VONINO policy.

The purpose of this document is to describe:

• The structure for the management of Health, Safety and Environmental (HSE) within the VONINO divisions.

• The expectations for each element of the HSE Management System.

It is the responsibility of each division to determine how these expectations and requirements are to be achieved.

Health, Safety and Environmental Policy

Our goal is to protect our people, the public, our property and the environment in which they work and live. It is a commitment that is in the best interests of our customers, our employees and all other stakeholders.

It is possible to run all operations without injuries or damage to equipment or the environment:

• We will comply with all applicable laws and relevant industry standards of practice.

• We will continuously evaluate the Health, Safety and Environmental (HSE) aspects of our equipment and services.

• We believe that effective HSE management is good business and we are committed to the continuous improvement of HSE management practices.

• From top management through to entry level, everyone is responsible and accountable for HSE.

We are committed to the integration of HSE objectives into our management systems at all levels. This will enhance our business success by reducing risk and adding value to our services.

Our Mission

Dragos Vasile| Executive Manager,

"To strive for global excellence in providing state of art high tech devices worldwide.

To distinguish ourselves through listening, learning and understanding industry challenges and to capitalize on strategic and opportunistic possibilities.

To provide services that are attractive and fair to our customers and earn their loyalty while also providing value to our shareholders.

To create a work place that protects worker health and safety with due respect for the environment, and promote an atmosphere to grow employ-ee learning and opportunity in a way that is fulfilling, recognized and fairly rewarded."

VONINO is striving for no safety incidents, no injuries, no days off work due to accidents. A perfect HSE record. Say No! to Injuries is a program that aims to prove that every danger can be avoided.

Saying No! to injuries is a decision to improve our attitude and outlook to ensure safety is always at the forefront for every employee. We expect our workers to make safety on-the-job and off-the-job an everyday priority by emphasizing five safety principles:

• Participation

• Accountability

• Consistency

• Communication

• Training

At VONINO, we expect people to come to the job site and for the duration of their stay, not have any injuries. We promote an environment in which injuries can be prevented with ease, in which responsibility is key, in which you’ll know what to look out for.

Saying No! to injuries does not mean they won’t happen, it means a commitment to working as many hours as possible without an injury. And it requires an attitude that says any injury or incident, even a small one, shouldn’t be taken lightly. Any incident is preventable, you just have to Say No!

It’s an attitude that we expect from each employee at VONINO.

HSE Management System

The VONINO HSE Management System defines the elements by which we will conduct our operations worldwide in order to protect our people, the public, our property and the environment in which they work and live.

The HSE Management System model is comprised of seven interrelated elements with underlying expectations:

1. Commitment and Leadership

2. Policies and Objectives

3. Organization, Resources and Documentation

4. Risk Evaluation and Management

5. Planning

6. Implementation, Recording and Monitoring

7. Audit and Review

Each division must communicate these expectations to all employees, customers and third parties associated with our business. Each division must provide positive evidence of conformance to this Management System and continuous improvement.

• Delegate the necessary authority to the appropriate personnel and allocate resources to carry out HSE functions.

• Visit operations on a regular basis to demonstrate commitment and recognize performance in HSE matters.

• Hold those in positions of authority accountable at all levels of the company for compliance with company policies and global standards.

• Develop HSE objectives at your level of responsibility.

• Communicate with employees, clients, subcontractors and industry personnel so that they know and understand the intent of HSE policies.

• Celebrate and promote your HSE success.

2. Policies and Objectives

Say what you are going to do. Develop and communicate policies demonstrating a commitment to HSE that is consistent with, and at least equal to, other business aims. Supporting objectives shall be defined, deployed and maintained at all organizational levels.

Expectations

• Develop local HSE policies that support and are consistent with corporate standards.

• Set objectives for continuous improvement.

• Involve all levels of management and personnel in the development of objectives for the division.

• Develop specific objectives for the reduction of risk.

• Communicate the policies and objectives to all employees in a clear, readily understood, medium.

• Appoint and support a management team representative to act as the focal point for HSE matters.

• Ensure that each group and individual receives sufficient information and training to fulfill their role with respect to HSE.

• Allocate sufficient resources to support policies and work towards achieving objectives set for HSE issues.

• Ensure a system that provides and maintains effective procedures, resource material and records on HSE subjects.

4. Risk Evaluation and Management

Continually evaluate the HSE risks to the workforce, customers and the environment. Continually evaluate processes and activities for specific hazards – assess potentials, record and control the subsequent risk to a tolerable level.

Expectations

• Establish a methodology that identifies both acute and chronic hazards and their associated impacts. Address routine and non-routine tasks, emergencies and outside influences.

• Control hazards and reduce risk to a tolerable level through mitigating and recovery measures.

• Apply risk management tools to all proposed activities including acquisitions, bids and new business development.

5. Planning

HSE considerations shall be integral to all aspects of business planning or changes in the design, development, purchasing and delivery of our products and services.

Expectations

• Identify and evaluate the consequences to health, safety and the environment when making changes to organizational structure, personnel, equipment, processes or procedures.

• Assign responsibility for the achievement of HSE objectives in plans at all levels of the organization.

• Determine the resources required to achieve the plan.

• Identify the means by which the plan is to be achieved.

• Set a time scale and develop milestones for implementation.

• Develop contingency plans for emergencies and in cases when plans or objectives cannot be completely achieved.

• Regularly review and follow up on progress towards achieving the HSE plans and objectives.

6. Implementation, Recording and Monitoring

Do what you said you would do. Determine and record whether those actions are effective. Activities shall be conducted in accordance with defined standards, and continuous improvement shall be promoted and monitored through active employee participation.

Expectations

• Assign necessary resources and authority to groups or individuals to implement plans, processes, procedures and work instructions.

Prove you did what you said you would do. Is the Management System achieving results and fulfilling policy intent? Audits and reviews shall be conducted to verify the implementation and effectiveness of the HSE Management System and its conformation to this specification.

Expectations

• Set frequency and level for audits for each division or operation.

• Document and distribute the audit report for corrective action and future reference. Review with all affected employees.

Our internal audit is intended to cover CSR creates an understanding of the social responsibility issues that affect the organization and its industry.

The draft consists of two main sections; a description of the CSR system architecture, and stakeholder factors. The CSR system architecture covers CSR policy, board responsibility, and codes of conduct, corporate governance, stakeholder engagement, environmental management, and complaints. The stakeholder factors section is divided into six sub-sections: employees & contract staff, shareholders, clients & customers, local inhabitants, suppliers, and the general public.

Following that, it review how management reconciles these sometimes-contrary needs and it cover the following :

Environment: Incorporation of environmental considerations into the manufacturing and distribution of products, and into their use and disposal

Community Involvement: Impacts on local communities, contribution to social and economic development, General interest causes.

Internal audit schematics

Action steps

Step 1: Situation Analysis –Questionnaire

– Have we violated any of our Corporate Social Responsibilities?

If so, why? What happened? Who else knows about these violations?

– What about any of our suppliers? What about any of our buyers? What about any of your direct competitors? Have any of them ever violated any of their responsibilities? Why?

Note: We are now in process of developing a Supplier Booklet of Conduct aiming to create the awareness of Advanced Technologies high values to all the suppliers . The booklet content is designed to promote worker safety and fairness, environmental responsibility, and ethical business. We are targeting suppliers who can review the booklet regularly to reflect best practices . Educating smaller component suppliers that don’t have strong sustainability programs can be more of a challenge.

– What is our mission statement and how does it align with our responsibilities to the community and stakeholders? What about our goals? What about our corporate values? Does our business plan reflect what we are finding?

– What does your community and stakeholders think about your company? What about your industry?

What about your competitors? What about your end users, your customers? – Are your findings positive or negative? What are the trends and direction?

Step 2: Benchmark

– Describing and defining the ethical standards and norms in our industry.

– Evaluating how the corporate code of conduct come about.

Short assessment to our employees about their feedback regarding how we used to share and communicate our corporate code of conduct with them. Based on the assessment results we are deciding the eventual amendments to the code of conduct.

– What are your direct competitors doing in respect to social cause programs?

– Which social cause programs have worked in your industry? Why?

– Which social cause programs have not worked in your industry Why not?

– What does the future, the trend analysis, indicate for your industry?

– What other significant trends are shaping your industry? What about regulations that may impact your industry? How did they come about? What is their root cause?

– How are companies in other industries complying with their social responsibilities that are similar to yours?

Step 3: Brainstorm

– Based on your findings and discovery above, what can you do differently, to strategically set your company apart?

– What do you want to do better? What things need improvement at your company? – What do you want to continue doing? What are the things you are doing better than your competitors?

– What area of your community, or who in the community, is most affected by your business? How?

– What community issues are likely to affect your business and/or employees?

– What role does your company want to play in the community?

– What have you done in the past to help this relationship?

– What are your employees’ interests and to which social causes are they committed?

– Does your business plan, business strategy fit well with what you are uncovering so far?

– Does your business plan, business strategy need to be reworked?

– What would be the timeline on getting your plan and strategy revised?

– Who could help you with this process?

Step 4: Evaluate Alternatives

Consider each one of these alternatives: Sponsorship, co-branding, licensing, new product promotion, philanthropic investments, donations of products and services, and employee involvement.

– Which one(s) seem best for your situation analysis? Why?

– What does your corporate leadership team think? What do your employees think?

– How are you going to evaluate and measure the outcomes for your social cause initiatives?

– What kind of resources are you willing to commit? For how long?

– How will you know you are doing well? Who is going to be the judge of that?

– How are you going to get your employees motivated and passionate to get behind your choice?

– How are you going to select an alternative? Who is going to help you select?

Step 5: Create the Action Plan

– What are the key talking points of your audit you feel you need to communicate right now?

– Do you feel you are you going on the “offensive?” Or the “defensive?” Why?

– Which social cause initiative looks like the best answer for your situation? Why?

– What are some of your deadlines to get started? How fast should you be moving on this?

– What moves do you think your direct competitors will do once you launch your social cause initiative or program?

– With whom should you be sharing your audit? How are you going to share your audit? – What do you expect them to feel, to think and to do once they read your audit?

– What do you need to share and when–with your internal stakeholders, executives, employees, investors, etc.? With your external stakeholders, suppliers, buyers, local communities, and the media?

– Who can help you prepare a summary of your corporate social responsibility audit?

– Who is going to be the person in charge of creating and launching your new social cause initiative?

Social Audit

It’s a process that measures ADVANCED TECHNOLOGIES social activities (i.e. those that affect its immediate community and society) in how:

• Employees and other stakeholders perceive the organization;

• The organization fulfills its aims;

• The organization works within its own value statements.

ADVANCED TECHNOLOGIES social auditing assesses the social impact of its organization in relation to its aims and those of its stakeholders. It’s founded on the principles of disclosure and openness, as the dialogue with stakeholders has to be mutual, continuous and honest.

Ethics

• Anti-corruption is the most important ethical issue in a CSR context for ADVANCED TECHNOLOGIES. Anti-corruption is included in the organization’s risk assessment, code of conduct, and policies.

• ADVANCED TECHNOLOGIES has a reporting system for stakeholders to report concerns or allegations of ethics violations.

• ADVANCED TECHNOLOGIES has investigation standards or protocols in place to gather evidence, manage cases, and protect the rights of parties involved in the investigation. The process is credible.

• Disciplinary action is appropriate and consistent.

• ADVANCED TECHNOLOGIES has a process for disclosure of conflicts of interest.

• The acceptance or constraints documented and conditions are monitored.

• ADVANCED TECHNOLOGIES has methods to provide ethics advice, training, and awareness to help stakeholders understand the organizations principles, processes, and practical application of the Code of Conduct.

• The ethics program performance measures and metrics are maintained and reported. The benchmarking and trend analysis performed are reported to senior management and the board.

Business Integrity

Fair competition is very important for ADVANCED TECHNOLOGIES. The highest standards of integrity are to be expected in all business interactions. ADVANCED TECHNOLOGIES does not accept any form of corruption, extortion or embezzlement. The supplier hereby fully adheres to all applicable competition and anti-bribery laws and regulations and rejects, amongst others, price fixing and market sharing arrangements.

No Improper Advantage

Bribes or other means of obtaining undue or improper advantage are not to be offered or accepted.

Disclosure of Information

Means to effectively safeguard customer information regarding business activities, structure, financial situation, performance, and/or any other information deemed confidential shall be disclosed only in accordance with the guidelines specified within any agreed upon non-disclosure agreement between Supplier and ADVANCED TECHNOLOGIES and within the guidelines of all applicable laws and regulations.

Intellectual Property

Suppliers shall have a policy not to use intellectual property, such as copyrights, trademarks, patents or software belonging to customers, without explicit permission. As well, suppliers will refuse to acquire commercial information by dishonest or unethical means, such as industrial espionage.

Protection of Identity

Suppliers shall have programs in place that ensure the confidentiality and protection of whistle blowers. A whistle blower is defined as any person who makes a disclosure about improper conduct by an employee or officer of a company, or by a public official or official body.

Privacy

Suppliers are committed to protecting the reasonable privacy expectations of personal information of everyone suppliers do business with, including suppliers, customers, consumers and employees.

Comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.

Environment

In ADVANCED TECHNOLOGIES, social and environmental impact assessments are performed:

• As part of risk management programs.

• As part of investment decision-making and approval processes.

• They include conflict risk.

• Incidents are reported, managed, and resolved appropriately.

• Environmental program performance measures and metrics are maintained and reported.

• Benchmarking and trend analysis are also performed and reported to senior management and the board.

• The results of audits — internal, regulator, and external are reviewed and commitments monitored and tracked to completion.

• ADVANCED TECHNOLOGIES has environmental emergency plans. These plans balance privacy of personal information with access to information for employees and the community.

Prevention of Pollution

• Use sustainable business practices and processes that minimize waste and prevent pollution, conserve energy and minimize health and safety risks, and dispose of waste safely and responsibly.

Product Environmental Leadership

• Conserve natural resources by developing products and packaging that minimize materials usage, use recycled and environmentally preferable materials, and that maximize reuse and recycling opportunities at the end of the product’s life.

• Develop, manufacture, and market products that are energy efficient and that minimize their impact on the environment.

• Be an environmentally responsible neighbor in the communities where we operate and act promptly and responsibly to correct conditions that may endanger health, safety, or the environment.

• Provide appropriate resources to fulfill these objectives.

Corporate strategies, policies and guidelines must support this commitment to leadership in environmental affairs. Every employee and contractor of Advanced Technologies must follow this policy and report any environmental, health, or safety concerns to Advanced Technologies management, who must take prompt corrective action.

Health, Safety, and Security

In ADVANCED TECHNOLOGIES, health and safety risk assessments are performed as part of investment decision-making, product development, and approval processes. They include conflict risk and workplace violence.

• Health and safety management programs are included in procurement processes.

• Incidents are reported, communicated, managed, and resolved appropriately. The results of incident investigations and resolution are appropriately reported with the recognition of personal information protection.

• Health and safety program performance measures and metrics are maintained and reported. The benchmarking and trend analysis are also performed and reported to senior management and the board.

• The results of audits — internal, regulators, and external — are reviewed and commitments monitored and tracked to completion.

• Stakeholders are provided with sufficient information to make informed decisions about health and safety risks.

Advanced Technologies is committed to creating and maintaining a workplace that provides for employee health and safety.

Corporate strategies, policies and guidelines must support this commitment to employee health and safety. The requirements listed below apply to all of Advanced Technologies’s worldwide operations. Every Advanced Technologies organization must support this policy and each manager and employee, as well as any contractor performing work on the behalf of Advanced Technologies, shall bear a personal responsibility for the following objectives.

• Provide a safe and healthful workplace for our employees.

• Provide products and equipment that are safe for use by our employees.

• Meet applicable legal requirements and voluntary practices to which we subscribe that are aimed at protecting our employees.

• Full support for employee health and safety through education, prevention and controls is vital to our innovation, productivity and continual improvement.

Labour, Human Rights and Work Conditions

ADVANCED TECHNOLOGIES is committed to maintaining and improving systems and processes to avoid complicity in human rights violations related to our own operations, our supply chain, and our products. We regularly assess human rights-related risks and potential impacts, review our policies and management processes, and seek input from stakeholders on our approach. We also support the advancement of human rights through our global efforts to help bridge the digital divide, expand education access, promote social innovation, and improve conditions in our supply chain.

Diversity and Nondiscrimination: ADVANCED TECHNOLOGIES respects, values and welcomes diversity in its workforce, its customers, its suppliers and the global marketplace. ADVANCED TECHNOLOGIES will comply with applicable laws and provide equal employment opportunity for all applicants and employees without regard to race, color, religion, sex, national origin, age, disability, medical condition, marital status, pregnancy, gender, gender expression, gender identity, sexual orientation, or any other characteristic protected by local law, regulation, or ordinance. This applies to all areas of employment.

Harassment Prohibition: ADVANCED TECHNOLOGIES is committed to providing a workplace free of sexual harassment as well as harassment based on factors such as race, color, religion, sex, national origin, age, disability, medical condition, marital status, pregnancy, gender, gender expression, gender identity, sexual orientation, or any other characteristic protected by local law, regulation, or ordinance. ADVANCED TECHNOLOGIES will not tolerate harassment of employees by managers or co-workers. ADVANCED TECHNOLOGIES employees are expected to treat co-workers, customers, and suppliers with dignity.

Workplace Safety and Environmental Quality

ADVANCED TECHNOLOGIES is committed to achieving high standards of environmental quality and product safety, and to providing a safe and healthful workplace for our employees, contractors, and communities. ADVANCED TECHNOLOGIES will seek to provide a secure business environment for the protection of our employees, product, materials, equipment, systems and information. We strive to comply with all applicable regulatory requirements as a minimum, and implement programs and processes to achieve greater protection, where appropriate. We support a precautionary approach to the materials used in our products; strive to conserve energy, water, and other natural resources; and reduce the environmental burden of waste generation and emissions to the air, water and land. We will be a responsible member of the communities in which we live and work. We are committed to transparent communication and maintain community advisory panels and community perception surveys to regularly obtain stakeholder input.

Prevention of Child or Forced Labor

ADVANCED TECHNOLOGIES will not employ anyone under the age of 16 in any position, and workers under the age of 18 should not perform hazardous work. ADVANCED TECHNOLOGIES expects its suppliers to comply with this expectation. Intel will not allow forced, debt bonded, indentured labor practices, or human trafficking, and we forbid harsh or inhumane treatment, including corporal punishment or the threat of corporal punishment.

Child and forced labor are prohibited within Advanced Technologies.

Working Hours and Minimum Wage Standards: Workweeks are not to exceed the maximum set by local law. ADVANCED TECHNOLOGIES expects employee compensation to comply with applicable wage laws, including those related to minimum wages, overtime hours, and legally mandated benefits.

Forced Labour - No forced or compulsory Labour under any conditions

Advanced Technologies does not engage or support the use of forced and compulsory labour.

The terms & conditions of employment are communicated prior to recruitment.

Freedom of Association & right to collective bargaining – Advanced Technologies respects the right of all employees to form and join trade unions of their choice & to bargain collectively.

ADVANCED TECHNOLOGIES has a security program, and has it considered human rights when developing and implementing security measures, especially in conflict regions.

ADVANCED TECHNOLOGIES has effective policies and programs to prevent and manage discrimination and harassment. ADVANCED TECHNOLOGIES has labor standards in place (child labor, forced labor, working hours, employment equity, and diversity)

ADVANCED TECHNOLOGIES accepts freedom of association and the right to collective bargaining for employees.

Compensation based on performance

For highly motivated employees, performance-driven compensation based on business goals and long-term incentives is one of the most important material requirements. Remuneration is based on job performance and the level of responsibility vested in the individual employee.

Part of the orientation bonus is based on the company’s performance while the other part is determined by the individual’s job performance and the meeting of set targets.

The remuneration of our employees is based on national laws. In addition, we offer employees performance- bonus, healthcare assurance.

Advanced Technologies complies with the national laws and regulations regarding working hours, wages and benefits.